1

United States

ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460

AGENCY USE

ONLY

OMB Control No.: 2060-

0226

Expires: 06/30/2011

SNAP INFORMATION NOTICE

For Significant New Alternatives

Date of Receipt:

Date 90 Day Review

Begins:

Date Review Completed:

CBI Status:

When completed send this form to:

Via US Postal Service: Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER SNAP DOCUMENT CONTROL OFFICER

OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA

U.S. EPA 1310 L STREET NW

1200 PENNSYLVANIA AVE NW 10th FLOOR (MC 6205J)

WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: Document Control

Number

INTRODUCTION

GENERAL INSTRUCTIONS

This form may be used to submit information under the Significant New Alternatives Policy (SNAP) program for the review of

alternatives to class I and class II ozone-depleting substances (ODS) under section 612 of the Clean Air Act. Submitters are required to

provide this information on new substitutes to assist the Agency in assessing the acceptability of chemicals or processes that are

considered alternatives for ODSs. A separate notice must be filed for each alternative you are submitting.

All submissions must be provided in threecomplete copies. If information is to be claimed as confidential, all confidential information

must be excised from one of the copies, which will be placed in the public docket; the other two copies must include the confidential

material. If no claims of confidentiality are made for the submission, all copies must be identical.

manual

provides instructions on submitting a SNAP notice, asserting confidentiality claims, completing the notice form, sector-specific data

requirements, and submitting test data and supplemental information.

To facilitate Agency review of alternatives, this form must be filled out as completely as possible. Please provide all information

requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailable.

TYPE OF NOTICE (Check only one box)

Select the appropriate box identifying the type of notice submitted:

Manufacturer Submission: New alternative, Substance, or Formulation___________________________________________ X

Petition: New alternative, Substance, or Formulation__________________________________________________________

Petition: Revision of the Existing SNAP list__________________________________________________________________

Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________
2

You must provide the identity of the alternative chemical of

processes and the identity and percentages of all

components in a blend and/or process, even if you claim the

identity as confidential. You may authorize another person

to submit the identity for you, but your submission will not be

complete and review cannot begin until EPA receives this

information.

Part II- ALTERNATIVE-SPECIFIC INFORMATION

Please indicate the sector(s) for which you are submitting

information on the substitute by checking the appropriate

boxes:

ü Refrigeration and Air Conditioning

ü Foam Blowing ___

ü Solvent Cleaning ___

ü Fire Extinguishing X

and Explosion Prevention

ü Sterilization ___

ü Aerosols ___

ü Adhesives, Coatings, and Inks ___

ü Tobacco Expansion ___

ü Pesticides ___

You may need additional copies of Part II if there are several

manufacturing, processing, or use operations that you will

describe in this notice. Please reproduce these sections as

needed.

If you substitute is also subject to review under FIFRA,

provide the FIFRA Registration Number:

______________

Part III- RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary.

Part IV- LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on the

form to fully answer a question. Label each continuation sheet with the

corresponding section heading and the question. In part IV, list these

attachments and any test data, other data, or any optional information

that you include in this notice.

TEST DATA AND OTHER DATA

You are required to submit all test data in your possession or control and

to provide a description of all other data known to you if these data are

related to the health and environmental effects of the manufacture,

processing, distribution in commerce, use, or disposal of the alternative.

Standard literature citations may be submitted if they do not appear in the

open scientific literature. Complete test data (in English), not summaries

of data, must be submitted if they do not appear in the open literature.

The following are test data and other data that might be submitted (see

the Guidance Manual for a more complete list of data to be submitted.)

Please indicate test data to be included in your submission notice by

checking the appropriate boxes:

Health Effects Data X Yes No ___

Flammability Data X

Environmental Effects

Data X

Environmental Fate

Data

Risk Assessments

Test Data Not in the Possession/

Control of the Submitter

Other Data X

You must provide the identity of the alternative

chemical of processes and the identity and

percentages of all components in a blend and/or

process, even if you claim the identity as

confidential. You may authorize another person

to submit the identity for you, but your

submission will not be complete and review

cannot begin until EPA receives this information.

CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentiality at the time of submission for any data which are to be treated as

Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information claimed as CBI

will be treated in a manner consistent with 40 CFR Part 2, Subpart B. Failure to assert a claim of confidentiality at the time of submission

may result in disclosure of information by the Agency without further notice.

To assert a claim on this form, circle or bracket the information you claim as confidential and mark the confidential box atthe bottom of

the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confidential, you must

nformation on claiming

information as confidential, please see the Instructions Manual.

Information submitted as CBI may be accessed by companies designated as Authorized Representatives of the United States

Environmental Protection Agency (EPA) under anEPA contract for the purpose of assisting EPA in the development and implementation

of national regulations for the protection of stratospheric ozone, including the development of the SNAP program. These Auth orized

Representatives may have access to any information received by the Stratospheric Protection Division within EPA Office of the

Atmospheric Programs for use in reviewing the need for possible control of any substance, practice, process or activity thatmay

reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary to ensure that these companies can

complete the work required by the contract.

Authorized Representatives of the Administrator are subject to the provisions of 42 U.S.C. 7414(c) respecting confidential business

information as implemented by 40 CFR 2.301(h).

Yes No ___

Yes No ___

Yes ___ No ___

Yes ___ No ___

Yes No ___
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Part I- GENERAL INFORMATION

Section A- SUBMITTER IDENTIFICATION

1. (a) Person Submitting Notice (in U.S.)

_____________________________________________________________________________________________________________

Name of Authorized Official Title

J.G.L. Aaldering Managing Director

____________________________________________________________________________________________________________

Company/Organization

DSPA.nl BV

____________________________________________________________________________________________________________

Mailing Address Telephone & Fax Numbers

DSPA.nl BV

Postbus 6572

T +31 (0) 24 37 89 581

TheNetherlands F +31 (0) 24 37 87 583

E-mail. j.aaldering@dspa.nl

Internet. http://www.dspa.nl

Chamber of Commerce. 39060741

VAT. No. NL 007677443B01

(b) Agent (if applicable)

Jim Hoptry VP-Operations

Name of Authorized Official Title

E4 Safety Products,LLC ____________________________________________________________________

Company/Organization

6767 Huntley Road Columbus , Ohio 43229 Phone(614) 431-5103 Fax (614) 839-9252

Mailing Address Telephone & Fax Numbers

(c) Joint Submitter (if applicable)

____________________________________________________________________________________________________________

Name of Authorized Official Title

____________________________________________________________________________________________________________

Company/Organization

____________________________________________________________________________________________________________

Mailing Address Telephone & FaxNumbers

2. Technical Contact (in U.S.)

Joseph Kuesis Director

__________________________________________________________________________________________________________

Name of Authorized Official Title

_________________________________________________________________________________________________________

Company/Organization

E4 SAFETY PRODUCTS LLC

6767 HUNTLEY ROAD COLUMBUS,

OH 43229

USA Phone (614) 431-5103

Fax (614) 839-9252

__________________________________________________________________________________________________________

Mailing Address Telephone & Fax Numbers

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter,

April 1, 2011 Phone conversation and emails

April 20,2011 In-person in Columbus, OH

Margaret Sheppard

Mark (X) if None ________________

Mark (X) this box if this page contains CBI __________

6503 Nijmegen
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Part I- GENERAL INFORMATION (continued)

Section B- ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative: OK, No CBI in this box.

1.) DSPA, 2.) Dry Sprinkler Powdered Aerosol, 3.) FIT 5, 4.) FIT, 5.) Fire Interruption Technology

2. (a) Name of chemical(s) (preferably IUPAC nomenclature and/or process name. For blends, provide the percent composition of each

constituent.

(b) Chemical Abstracts Service (CAS) registry number and molecular formula.

(c) For alternative processes and technologies describe the technology and provide a diagram of the system. Also provide the information on

any chemical constituents.

(d) If you hold a patent on the substitute, provide the patent name and number and include a copy of the patent as an attachm ent. If you

have submitted a patent application but have not been granted one yet, indicate the date submitted and the expected time frame for a response.

CONFIDENTIAL

3. Generic chemical name (if chemical name of substitute is declared Confidential Business Information). OK, No CBI in this box.

Answer: DSPA GENERATOR

4. Specific End-Use OK, No CBI in this box.

(a) Describe each end-use that may be reasonably anticipated for the alternative. Be sure to provide a broad description (e.g. terpene-based

semi-aqueous solvent cleaner for electronic parts, or HFC substitute refrigerant for centrifugal chillers).

For a list of end uses, see Appendix A to the instructions, beginning on p. 19.

Answer: DSPA generators are used for fire and explosion suppression as a replacement for Halon 1301 Total Flooding Agents. DSPA

mobile generators (streaming) are intended for use in ships and industrial buildings and by fire departments as a first action to

suppress A, B, C and K Class fires in enclosed areas and as fixed installations in all industrial and commercial structures and in the

transport sector (trains, trucks, cars, and ships) as a replacement or to augment current fire suppression systems already in -place for

normally unoccupied spaces.

(b) Identify the ODS and the quantity of substitute (if applicable) needed to replace it for each end use in pounds (replacement ratio).

Answer: NA. There are no Ozone depleting substances contained per the EPAlists of all ozone-depleting substances (ODS)

recognized bythe Montreal Protocol including ODP and GWP.

Mark (X) this box if this page contains CBI X
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Part I- GENERAL INFORMATION (continued)

Section B- ALTERNATIVE IDENTIFICATION (Continued)

5.

(a) Identify each impurity that may reasonably be anticipated to be present in the chemical alternative as manufactured for

commercial purposes. If there are unidentified impurities, e

(b) Provide the CAS Registry Number if available.

(c) Estimate the maximum weight percentage of each impurity. If there are unidentified impurities, estimate their total weight

percentages.

CONFIDENTIAL

6. By-products

(a) Describe anyby-products of degradation products resulting from the manufacturer, processing, use or disposal of the

chemical alternative or chemicals used in the new alternative. If there are unidentifiedby-products/ degradation products enter

(b) Provide the CAS Registry Number if available.

(c) Indicate where theby-product/degradation product is formed (e.g. during manufacturing, during use, etc.) and the amount

or rate at which it is formed.

CONFIDENTIAL

Mark (X) this box if this page contains CBI X
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Part II- ALTERNATIVE-SPECIFIC INFORMATION

Section A- PHYSICAL AND CHEMICAL PROPERTIES

1. Molecular weight 2. Physical state at 20°C

3. Melting point 4. Boiling point at 1 atm. Pressure

5. Specific gravity 6. Odorthreshold mg/m3

7. Solubility using solvent @ temperature

8. Solubility in water @ temperature

9. Partition coefficient Log Kow Log K

10. Vapor pressure @ 20°C psi 11. Critical temperature 12. Critical Pressure psi

13. Are spectra attached? 14. Disassociation constant

1. Particle size distribution 16. Volatilization from soil

17. Volatilization from water 18. Viscosity @ 20°C

19. pH concentration 20. Thermal conductivity

21. Adsorption coefficient 22. Flammability limits (LFL, UFL) % vol

23. Flash point 24. Heat of combustion

25. Maximum pressure rise 26. Maximum rate of pressure rise

27. Other (specify)

28. Provide any information on flammability concerns. For example, if any abatement techniques are being used to minimize the risks

associated with flammable substances or mixtures, detail those techniques below. If a substitute is flammable, an assessment of overall risk

in eachend-use may be required. (SeeInstructions for sector-specific data requirements for flammable substances).

CONFIDENTIAL.

Mark (X) this box if this page contains CBIX
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1. Ozone-depletion potential (ODP):

(a) Provide the 100 year ODP of the alternative relative to CFC-11, if known. If the substitute is a blend, provide the ODPs of

individual constituents.

Answer: NA. There are no Ozone depleting substances contained per the EPAlists of all ozone-depleting substances

(ODS) recognized by the Montreal Protocol including ODP and GWP.

(b) Provide source of ODP or any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromine

loading potentials). Reference thesource of this information and attach any supporting documentation.

Answer: Source: EPA website and EPA documents pertinent to all ODPs recognized by the Montreal Protocol and the

EPA including ODP and GWP.

2. Global Warming Characteristics:

oxide over 100- and 500-year time horizons, if

known. If the substitute is a blend, provide the GWPs of the individual constituents.

(b) If known, provide th -

X%) and results of any testing ormodelling done (both theoretical and actual testing).

(c) Provide source of GWP or any additional data on the GWP of the alternative, including the atmospheric lifetime, infrared

absorption spectrum, and infrared absorption capacity. If the alternative (e.g. CO2 captured from a stream of waste gas as a byproduct of fermentation).

Not Applicable

Mark (X) this box if this page contains CBI __________

Part II- ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B- ATMOSPHERIC INFORMATION
8

Part II- ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section C- OTHER STATUTES AND STANDARDS

1. Describe whether and how the alternative is regulated under other environmental regulatory statutes, for example other titles

under the Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Drinking Water Act (SDWA), the Resource Conservation

and Recovery Act (RCA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Toxic Substances Control Act

(TSCA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Emergency Planning and

Community Right-to-Know Act (EPCRA, also known as SARA Title III), and state and local laws. List any concentration-based or

other numerical standards to which the alternative is subject under the above standards and regulations.

Not Applicable

2. Describe whether and how the alternative is regulated under health and safety related statutory authorities, such as those

implemented by the Food and Drug Administration (FDA), the Occupational Safety and Health Administration (OSHA), the

Department of Transportation (DOT), and state and local laws. List any concentration-based or other numerical standards to

which the alternative is subject under the above statutes and regulations. Also list any other standard-setting organizations such

as the National Fire Prevention Association (NFPA) or the American Society of Heating, Refrigerating, and Air Conditioning

Engineers (ASHRAE), by which the substitute is evaluated.

NFPA 2010

UL 2127, "Inert Gas Clean Agent Extinguishing System Units,"

ULC Subject C1500, "Aerosol Generating Fire Extinguishing System Units.

See Attachment B.112

Mark (X) this box if this page contains CBI __________
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Part II- ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section D- COST AND AVAILABILITY OF THE ALTERNATIVE

1. Estimate the cost per pound for the substitute chemical. For alternative processes and technologies,describe installation

costs associated with the alternative.

CONFIDENTIAL

2. Provide information on production of the substitute. Include estimates on:

(a) Year substitute will be available if not currently produced.

(b) Total pounds production per year (current figure).

(c) Years to maximum market penetration.

(d) Maximum total production per year at market saturation.

(e) Estimated percentage of market at market saturation.

CONFIDENTIAL

3. Describe any new equipment and use profiles. If retrofitting of existing equipment is required, detail changes in technologies

needed to use the alternative and address any materials compatibility issues. Provide information on each end-use and capital

cost associated with the substitute or alternative process. Include cost of equipment and/or any new materials, equipment

lifetime, changes in labor and energy costs.

Not Applicable/ System does not require piping network

Mark (X) this box if this page contains CBI X
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Part III- RELEASE AND EXPOSURE DATA

Section A- TOXICITY AND HAZARD INFORMATION

For chemical alternatives and for chemicals used with alternative processes, summarize below (and attached supporting

information) the acute and chronic toxicity of the substitute and of its constituent chemicals on any organism (e.g. human and/or

other mammals, fish, wildlife, and plants), if available. Include any data on impurities and degradation products if known. Also

that have been set for the substitute for use in the workplace. In

addition, please attach a copy or facsimile of any hazard warning statement, label, material safety data sheet, or other

information which will be provided to any person who is reasonablylikely to be exposed. (See Guidance Manual for sectorspecific data requirements).

CONFIDENTIAL

Section B- ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site:

(a) Identify all site locations (i.e. name and address)for each chemical manufacturing process.

(b) Identify all site locations for manufacturing of products using substitutes (e.g. refrigerators containing the substitutes).

(c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products containing

the substitutes.

(d) Provide information on the magnitude of release if available, along with the media to which the substitute is released (e.g.

indoor air, outdoor air, water, land).

CONFIDENTIAL

Mark (X) this box if this page contains CBI x
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Part III- RELEASE AND EXPOSURE DATA

Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

For each manufacturing site (manufacturing of substitutes and/or products containing substitutes):

(a) Describe the activities in which workers may be exposed to chemicals.

Answer: Due to automatic production the workers will not exposed to chemicals during transportation, installation or

maintenance.

(b) Describe any protective equipment andengineering controls used to protect workers (e.g. goggles, gloves, chemical

hoods).

Answer: The production equipment and employees are qualified and meet all recent demandsconcerning safe working.

(c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas).

Answer: During manual processing the raw materials are solids

(d) Estimate average and maximum numbers of workers involved in each activity.

Answer: Maximum 2; average 1

(e) Estimate average and maximum duration of activity for any worker, in terms of (1) hour/day and (2) days/year.

Answer: Maximum 12h/day and 360 days/year. Average: 8h/day and 240 days/year

(f) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

Answer: Contact pathway possible by inhalation

(g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units of measure.

Answer: No exposure

Note: Not a USA based manufacturing and No USA based manufacturing facilities exist or are planned.

Section D- ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE

For each end-use of a substitute:

(a) Provide the estimated amount (in kg/day) of each chemical released directly to the environment (e.g. as a hazardous

waste or wastewater effluent) at a site using the substitute (e.g. in products containing the substitute and processes usingthe

substitute).

Answer: The generator consists of solid blocks that are not friable and are contained in rigid steel casing and unless

activated will not be normally released into the environment. The only time a release into the environment will occur is

when a unit is activated to suppress an ongoing fire.

(b) Identify the media (indoor air, outdoor air, land, water) towhich the chemical will be released from that release point.

(c) Describe the control technology used to limit release; estimate the amount released to the environment with the control

technology in place to limit release. If the substitute is to be disposed of, indicate the method and location of disposal.

Answer: The release of aerosol is necessary to suppress the fire

(d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes.

Answer: Trace amounts of some gaseous by-products are not covered under RCRA; these by-products are negligible.

(e) Identify the appropriate number of sites expected to use the substitute.

Answer: DSPA generators are most suitable for extinguishing of Class A and Class B fire in normally unoccupied areas

(f) Provide information on recycling of the substitute. Describe any associated costs and equipment.

Answer: Recycling is neither possible nor practical.

Mark (X) this box if this page contains CBI __________
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Part III- RELEASE AND EXPOSURE DATA (continued)

Section E- OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the substitute (end-uses utilizing the substitute in products and/or processes):

(a) Describe the activities in which workers may be exposed to chemicals.

Answer: Workers will not exposed to chemicals during transportation, installation or maintenance. The generator

consists of solid blocks that are not friable and are contained in rigid steel casing in which workers can have no direct

contact with the substitute

(b) Describe any protective equipment or engineering controls used to protect workers (e.g. goggles, gloves, chemical hoods).

Answer: Goggles or a cloth respirator maybe needed if the worker was in the room when the generator was activated,

otherwise, no equipment is needed.

(c) Indicate the physical form of chemicals at the time of handling/exposure (e.g. solid, liquid, gas).

Answer: During manual processing the raw materials are solids

(d) Estimate average and maximum numbers of workers involved in each activity.

Answer: Maximum 2; average 1

(e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year.

Answer: Maximum 12h/day and 360 days/year. Average: 8h/day and 240 days/year

(f) Enter the contact pathway (e.g. ingestion, inhalation, dermal).

Answer: Contact pathway possible by inhalation

(g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units.

Answer: No exposure

Section F- CONSUMER EXPOSURE

No consumer applications at this time for a Halon substitute

Mark (X) this box if this page contains CBI __________
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Part III- RELEASE AND EXPOSURE DATA (continued)

Section G- GENERAL POPULATION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes:

(a) Identify and number potential exposure points.

Answer: No potential exposure during manufacturing.

(b) For each exposure point described in (a), identify the potentially exposed population (e.g. residents at the fenceline).

Answer: Not applicable

(c) Identify the contact pathway (e.g. ingestion, inhalation, dermal).

Answer: Not applicable

(d) Identify the exposure medium (e.g. air, water).

Answer: Not applicable

(e) Enter the exposure point concentration (mg/m3). Provide (1) average and (2) high-end estimates.

Answer: Not applicable

Not manufactured in the USA

Mark (X) this box if this page contains CBI __________
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Part IV- LIST OF ATTACHMENTS

List below any attachments that complete the responses to the questions on this form or that provide additional information that

ready

submitted to EPA as part of past regulatory and information activities, as well as for other information thatcould not be included

with this submission. If you have attached continuation pages, describe the Part, Section and question number being continued.

Attach additional pages if necessary.

Attachment Name Question # Number of

Pages

CBI

RU 2150310C1 Part I; Section B;

2d

6

RU2153376C1 Part I; Section B;

2d

6

RU2164809C2 Part I; Section B;

2d

6

KIWA Nederland BV; DSPA Fire Protection System; Study on a

condensed aerosol 8-1 generator consisting of a solid aerosol forming

compound and a cooling mechanism

Part I; Section B;

5a

13 X

Experimental Detection of Combustion Components of the Aerosol

Solid Media of the AGS.

Part I; Section B; 6 4 X

MSDS DSPA Fixed Installation Generator Version 3.0 Part III, Section A 5

Comparison Chart ( DSPA compared to three different suppression

mediums)

Attachment B.111 1

Title 21- Food and Drugs

Chapter I- US Food and Drug Administration

Department of Health and Human Services

Subchapter B-Food for Human Consumption

Attachments

B.112, B.112.1,

B.112.2

3

DSPA Aerosol generator ULC witness tests / Hughes Associates Attachment B.113 21 X

Confidential Business Information Statement Attachment B.114 1 X

Live Specimen Test results / DSPA Aerosol Attachment B.115 5 X

BRE Global Test results Fire Suppression in a Prison Cell Attachment B.116 30 X

BRE Global- A UKAS member lab, part of ILAC Attachment B.117 2

Intertek - UL 711(modified) rating and Fire testing of Fire extinguishers Attachment B.118 3 X

Answers to Incomplete SNAP submission dated: 06-16-2011 Attachment B.119 9 X

EPA Requested DSPA mobile system testimonials Attachment B.120 2

Clarification of responses provided in the attachment to the revised

submission from 7/27/2011 Attachment B.121

Question A.1

1 Column s A

through F

X

Clarification of responses provided in the attachment to the revised

submission from 7/27/2011 Attachment B.121

Question A.2

1 Column G X

Quantity of agent needed to replace Halon 1211 in pounds (lbs.) Attachment B.122 1 X

Mark (X) this box if this page contains C
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46

Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGs.
47

Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGs.
48

Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGs.
49

Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGs.
50
51
52
53
54
55

Comparison chart

(Attachment B.111)

(Comparing DSPA to three known mediums of fire suppression agents)

DSPA Inert gas Halon 1301 CO2

Environmental damage None Low Very high Average

Toxicity

Evacuation

None

NO

Low high

YES

Low

NO

High

YES

Volume N/A >45% 5% 8-40%

Corrosion None Low Above average None

Concentration 50gr/m3 550 - 950gr/m3 200 - 350gr/m3 700-1500gr/m3
56

FDA

(Attachment B.112)

Title 21- Food and Drugs

Chapter I- US Food and Drug Administration

Department of Health and Human Services

Subchapter B-Food for Human Consumption

PART 184 -- DIRECT FOOD SUBSTANCES AFFIRMED AS GENERALLY RECOGNIZED AS SAFE

Subpart B--Listing of Specific Substances Affirmed as GRAS

Sec. 184.1619 Potassium carbonate.

(a) Potassium carbonate (K2CO3, CAS Reg. No. 584-08-7) is produced by the following methods of manufacture:

(1) By electrolysis of potassium chloride followed by exposing the resultant potassium to carbon dioxide;

(2) By treating a solution of potassium hydroxide with excess carbon dioxide to produce potassium carbonate;

(3) By treating a solution of potassium hydroxide with carbon dioxide to produce potassium bicarbonate, which is then

heated to yield potassium carbonate.

(b) The ingredient meets the specifications of the Food Chemicals Codex, 3d Ed. (1981), p. 240, which is

incorporated by reference. Copies are available from the National Academy Press, 2101 Constitution Ave. NW.,

Washington, D.C. 20418, or available for inspection at the National Archives and Records Administration (NARA). For

information on the availability of this material at NARA, call 202-741-6030, or go

to:http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.

(c) In accordance with 184.1(b)(1), the ingredient is used in food with no limitation other than current good

manufacturing practice. The affirmation of this ingredient as generally recognized as safe (GRAS) as a direct human

food ingredient is based upon the following current good manufacturing practice conditions of use:

(1) The ingredient is used in food as a flavoring agent and adjuvant as defined in 170.3(o)(12) of this chapter; nutrient

supplement as defined in 170.3(o)(20) of this chapter; pH control agent as defined in 170.3(o)(23) of this chapter; and

processing aid as defined in 170.3(o)(24) of this chapter.

(2) The ingredient is used in food at levels not to exceed current good manufacturing practice.

(d) Prior sanctions for this ingredient different from the uses established in this section do not exist or have been

waived.

[48 FR 52442, Nov. 18, 1983]
57

FDA

(Attachment B.112.1)

Title 21- Food and Drugs

Chapter I- US Food and Drug Administration

Department of Health and Human Services

Subchapter B-Food for Human Consumption

PART 184 -- DIRECT FOOD SUBSTANCES AFFIRMED AS GENERALLY RECOGNIZED AS SAFE

Subpart B--Listing of Specific Substances Affirmed as GRAS

Sec. 184.1135 Ammonium bicarbonate.

(a) Ammonium bicarbonate (NH4HCO3, CAS Reg. No. 1066-33-7) is prepared by reacting gaseous carbon dioxide

with aqueous ammonia. Crystals of ammonium bicarbonate are precipitated from solution and subsequently washed

and dried.

(b) The ingredient meets the specifications of the Food Chemicals Codex, 3d Ed. (1981), p. 19, which is incorporated

by reference. Copies are available from the National Academy Press, 2101 Constitution Ave. NW., Washington, DC

20418, or available for inspection at the National Archives and Records Administration (NARA). For information on

the availability of this material at NARA, call 202-741-6030, or go

to:http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.

(c) In accordance with 184.1(b)(1), the ingredient is used in food with no limitation other than current good

manufacturing practice. The affirmation of this ingredient as generally recognized as safe (GRAS) as a direct human

food ingredient is based upon the following current good manufacturing practice conditions of use:

(1) The ingredient is used as a dough strengthener as defined in 170.3(o)(6) of this chapter; a leavening agent as

defined in 170.3(o)(17) of this chapter; a pH control agent as defined in 170.3(o)(23) of this chapter; and a texturizer

as defined in 170.3(o)(32) of this chapter.

(2) The ingredient is used in food at levels not to exceed current good manufacturing practice.

(d) Prior sanctions for this ingredient different from the uses established in this section do not exist or have been

waived.

[48 FR 52439, Nov. 18, 1983]
58

FDA

(Attachment B.112.2)

Title 21- Food and Drugs

Chapter I- US Food and Drug Administration

Department of Health and Human Services

Subchapter B-Food for Human Consumption

PART 184 -- DIRECT FOOD SUBSTANCES AFFIRMED AS GENERALLY RECOGNIZED AS SAFE

Subpart B--Listing of Specific Substances Affirmed as GRAS

Sec. 184.1613 Potassium bicarbonate.

(a) Potassium bicarbonate (KHCO3, CAS Reg. No. 298-14-6) is made by the following processes:

(1) By treating a solution of potassium hydroxide with carbon dioxide;

(2) By treating a solution of potassium carbonate with carbon dioxide.

(b) The ingredient meets the specifications of the Food Chemicals Codex, 3d Ed. (1981), p. 239, which is

incorporated by reference. Copies are available from the National Academy Press, 2101 Constitution Ave. NW.,

Washington, DC 20418, or available for inspection at the National Archives and Records Administration (NARA). For

information on the availability of this material at NARA, call 202-741-6030, or go

to:http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.

(c) In accordance with 184.1(b)(1), the ingredient is used in food with no limitation other than current good

manufacturing practice. The affirmation of this ingredient as generally recognized as safe (GRAS) as a direct human

food ingredient is based upon the following current good manufacturing practice conditions of use:

(1) The ingredient is used as a formulation aid as defined in 170.3(o)(14) of this chapter; nutrient supplement as

defined in 170.3(o)(20) of this chapter; pH control agent as defined in 170.3(o)(23) of this chapter; and processing aid

as defined in 170.3(o)(24) of this chapter.

(2) The ingredient is used in food at levels not to exceed current good manufacturing practice.

(d) Prior sanctions for this ingredient different from the uses established in this section do not exist or have been

waived.

[48 FR 52442, Nov. 18, 1983]
59

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(Attachment B.114)

Claim of Confidential Business Information

All sections bracketed in RED are considered to be Confidential Business Information.

Part 1- General Information

Section B- Alternative Identification

1.) The information contained within contains company trademarks and copyrights.

2.) Chemical composition is considered a patented formula and proprietary intellectual

property. This information is not for public exposure as it would damage the business

Should it become public knowledge and be copied.

5A.) Private company test results, not for public dissemination.

6.) Chemical composition is considered a patented formula and proprietary intellectual

property. This information is not for public exposure as it would damage the business

should it become public knowledge and be copied

6c.) Chemical composition is considered a patented formula and proprietary

intellectual property. This information is not for public exposure as it would

damage the business should it become public knowledge and be copied

Part II Alternative specific information

Section A Physical and Chemical properties

1.) The physical and chemical properties of the product are patented and a proprietary

company formula. The characteristics and properties of the formula are also

considered proprietary and company intellectual property.

Section D- Cost and Availability of the Alternative.

1.) Any information pertaining to cost , manufacturing, sales and marketing are to

be considered private company information and strictly confidential.

Part III Release and Exposure

Section A Toxicity and Hazard information

Chemical composition is considered a patented formula and proprietary

intellectual property. This information is not for public exposure as it would

damage the business

Attachments- Company proprietary test results, not for public dissemination

KIWA Nederland BV; DSPA Fire Protection System; Study on a condensed aerosol 8-1

generator consisting of a solid aerosol forming compound and a cooling mechanism

Part I; Section B; 5a

Experimental Detection of Combustion Components of the Aerosol Solid Media of the AGS. Part I; Section B; 6

DSPA Aerosol generator ULC witness tests / Hughes Associates Attachment B.113

Confidential Business Information Statement Attachment B.114

Live Specimen Test results / DSPA Aerosol Attachment B.115

Live Specimen Test results / DSPA Aerosol Attachment B.115

BRE Global Test results Fire Suppression in a Prison Cell Attachment B.116

BRE Global- A UKAS member lab, part of ILAC Attachment B.117

Intertek - UL 711(modified) rating and Fire testing of Fire extinguishers Attachment B.118
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Attachment B.117

BRE GLOBAL, A MEMBER OF UKAS

United Kingdom Accreditation Service

ILAC - the International Laboratory Accreditation Cooperation - is an international

cooperation of laboratory and inspection accreditation bodies formed more than 30 years

ago to help remove technical barriers to trade.

Accreditation allows people to make an informed decision when selecting a laboratory, as it

demonstrates competence, impartiality and capability. It helps to underpin the credibility and

performance of goods and services.

Accreditation bodies around the world, which have been evaluated by peers as competent,

have signed an arrangement that enhances the acceptance of products and services across

national borders. The purpose of this arrangement, the ILAC Arrangement, is to create an

international framework to support international trade through the removal of technical

barriers.

laboratory and inspection accreditation bodies representing

more than 70 economies and regional organizations.

The ultimate aim of the ILAC Arrangement is the increased use and acceptance by industry as

well as regulators of the results from accredited laboratories and inspection bodies, including

results from laboratories in other countries. In this way, the free-trade goal of 'product

tested once and accepted everywhere' can be realized.

ILAC provides a focus for:

Developing and harmonizing laboratory and inspection accreditation practices

Promoting laboratory and inspection accreditation to industry, governments,

regulators and consumers

Assisting and supporting developing accreditation systems

Global recognition of laboratories and inspection facilities via the ILAC Arrangement,

thus facilitating acceptance of test, inspection and calibration data accompanying

goods across national borders

The following are US signatory members to ILAC:

1.) American Association for Laboratory Accreditation (A2LA)

2.) National Voluntary Laboratory Accreditation Program (NVLAP

3.) International Accreditation Service, Inc (IAS)

4.) ANSI-ASQ National Accreditation Board

5.) Laboratory Accreditation Bureau (L-A-B)

6.) Perry Johnson Laboratory Accreditation, Inc. (PJLA)

7.) American Society of Crime Laboratory Directors/Laboratory Accreditation Board (ASCLD/LAB)

8.) AIHA Laboratory Accreditation Program, LLC (AIHA-LAP, LLC)
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Attachment B.120

User Testimonials requested by the EPA

DSPA-5 Mobile systems

Intense Heat Dramatically Reduced in Basement Fire

March 2009

ROCKY MOUNTAIN HOUSE, AB

A thermal imaging camera helped make up the mind of Deputy Fire Chief Rob Shanks of the

Rocky Mountain House Fire Department. A temperature of 900° C threatened his crew as he

contemplated an interior attack on a basement fire in an Alberta home.

Choosing to deploy a DSPA-5 , Chief Shanks watched in amazement as the temperature

dropped to 400° C approximately 20 seconds after the DSPA-5 dispersed its powder aerosol.

The interior attach followed.

The fire was confined to the basement. The department estimates property savings at

approximately $100,000.

Attic Fire is No Match for DSPA-5

Saving Owner $80,000 in Property Damage

January 2009

SECHELT, BRITISH COLUMBIA

Hot wood ashes in a bucket by the wall of a garage were enough to kindle a fire that quickly

spread into the attic of the detached two-car structure. Fire Chief Bill Higgs quickly surveyed the

situation and made the decision to deploy a DSPA-5 through an attic hatch opening.

To his surprise, 15 to 20 seconds were enough to knock down the flames, leaving just a few hot

that the $20,000 loss to the structure is one-fifth of the amount that could have been lost

without the DSPA-5.

uation, the quick knock down of the fire by the DSPA-5 reduced our need to use

water on the structure and allowed our crew and trucks to return to the station in less than two

n in fire
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Attachment B.120

New Fire Fighting Device Saves the Day and the Structure

September 2008

HIGH RIVER, AL

A four-unit apartment fire provided one of the first opportunities for Alberta firefighters to

deploy DSPA-5 in a real-world setting. For the High River Volunteer Fire Department, the device

more than proved its worth.

Once introduced into the fire, the DSPA-5 quickly suppressed the flames and protected the

other three -

to 1,000 degrees to 300-

It was the H The Fire Within that resulted in its

receiving the first DSPA- The Fire Within supplying us with the DSPA-5, we were able

to deploy it at a working structure fire. It saved the building but it also decreased fire and water

January 2008

LEDUC, AB

A temperature of -56° F (-49°C) had frozen the hydrant solid and the house on fire outside

Edmonton, Alberta looked like a sure loss. The same fate seemed to await a nearby RV and

house.

Leduc firefighter Troy Mutch elected to use a DSPA-5 to see if he could buy time until a truck

arrived. Mutch later recalled that the DSPA-5 pulled the fire back into the house for almost

fifteen minutes, creating time enough for the truck to arrive and tamp out the last of the fire.

would have spread to the RV and adjacent house. Thanks to the DSPA-5, there was no damage

to either.
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Attachment B.121

Clarification of responses provided in the attachment to the revised submission Q-A.1
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Attachment B.122

Quantity of agent needed to replace Halon 1211 in pounds (lbs.)